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NGT - our statement to the public inquiry

New Generation Transport (NGT): Leeds Cycling Campaign's statement to the public inquiry

In outline, our objection is that the NGT scheme does little to improve the situation for cycling and walking, particularly as the scheme would travel along the most-cycled route in Leeds; that the assumptions underpinning NGT are unduly favourable to unsustainable and inefficient modes of transport while ignoring the potential of walking and cycling; and that NGT while overall slightly beneficial for cycling misses a huge opportunity to support the step-change in cycling that has been promised by Leeds and West Yorkshire authorities.

Introduction and consultation process so far

We are pursuing this objection whilst in discussion with the promoters about the detailed plans. I would like to acknowledge the positive discussions we have had with designers and their attempts to implement better provision for cycling within the limits imposed on them. The promoters make much of the consultation with cyclists, (as in argument 1 of their rebuttal) and of the changes they have made in response to comments by my members and other cyclists.

The reason for the continued objection is that while the NGT project contains some elements that improve the situation for cyclists, and while we welcome the changes that have been made to the plans in response to our concerns, we have several fundamental issues with both the principles underlying the scheme, and its detailed implementation.

To set this in context, plans for the modern incarnation of NGT were first presented to the council’s quarterly Cycling Consultation Forum in July 2012, at which point the bare minimum had been provided to support cycling: in some locations the proposed situation for cycling was actually worse than it is now. Any gains since then, while welcome, still fall far short of the standards we would hope for, in a city that recognises and values the benefits of cycling as a transport choice. The past has seen a catalogue of disappointments in the development of cycle infrastructure in Leeds, so I hope you will forgive my members’ scepticism about promises to include cycle-friendly measures at the detailed design stage.

Leeds City Region faces significant transport challenges in the coming years. The population of Leeds is forecast to increase substantially over the coming years, with thousands of new homes planned for East Leeds and the Aire Valley; North West Leeds including Cookridge and Adel; and Otley. This increase in population undoubtedly requires an increase in the capacity of our transport infrastructure.

One of the most effective ways to increase network capacity is to create a modal shift away from low-occupancy vehicles – the car with one or two passengers – to public transport, walking and cycling. This works because cars are a very inefficient way of moving people around cities. Even if every car had 5 occupants, bicycles are more efficient at moving through junctions, and pedestrians even more so. The OECD’s international transport forum cites research from MIT/Boston showing that a shift of just 1% of all journeys to cycling, led to an improvement of up to 18% in journey times for everyone – including those in cars and public transport.

So we can see that a shift to more sustainable transport supports the city region’s strategic objectives to reduce CO2 emissions, improves our health, and helps create liveable environments. It helps to ensure access to employment for households without a car – which is 34% of all households in Leeds and closer to 50% for some wards on the NGT route, and ensures that we can grow as a city without our transport system grinding to a halt.

The West Yorkshire Local Transport Plan (LTP) recognises this by including a target for the total number of car trips to be held at 2011 levels by 2026. To offset planned population growth, this will require real terms reduction in car trips in some areas, and the Plan suggests an increase in walking trips in the order of 20%, bus trips by 50%, and cycling trips by 300% to meet this target.

LTP also identifies “Six ‘big ideas’ that will drive progress towards the objectives. To focus on those most relevant to NGT and cycling:

3. Invest in low-carbon modes of travel by supporting the development of infrastructure for low carbon methods of travel, such as electric trains, ‘Park-and-Ride’, buses, tram-train, trolleybuses, walking and cycling.

5. Introduce stronger demand management measures to encourage less car use and ‘lock-in’ the benefits created by people changing to low-carbon modes.

Of journeys to work in Leeds that are less than 3 miles long, approximately 44% are currently taken by car. In a recent British Household Attitudes Survey, ‘Two-thirds of drivers [said] they are willing to cut their car use, and three in five would be able to shift from using the car on short journeys to cycling, walking, or taking the bus … the overall climate of public opinion can … be described as favourable towards a reduction in car use.’[i] The City of Helsinki leads the way, recently announcing its aim to make car ownership obsolete by 2025.

Leeds University’s annual travel survey in 2011, particularly relevant to NGT as the trolleybus route travels past the University and through areas with a relatively high population of University students and staff, found that about 8% of staff and 6% of students commute mainly by bicycle. In the same survey “Preferred commuting mode in an ideal world” (assuming same residence) is 16% of staff and 17% of students, showing a strong demand for cycling as a transport choice.

“Illness as an outcome of physical inactivity has been conservatively calculated to be £1.08 Billion per annum in direct costs to the NHS alone (2007 prices). Indirect costs have been estimated as £8.2 Billion per annum (2002 prices)”.[ii] A recent news report claimed that physical inactivity could bankrupt the NHS without prompt and effective interventions. Bodies such as NICE and public health organisations agree that active travel should form part of this intervention.

Research shows that provision of sustainable transport alternatives will ultimately fail unless there is significant encouragement to seek alternatives. Rather than a relationship between physical activity and availability of sustainable choices, a 2011 study commissioned by the DfT found that “the key relationship is between car use and physical activity. In order to increase levels of physical activity, it is necessary to reduce use of the car.”[iii]

Yet you have heard in this inquiry from Gordon Robertson among others, that NGT is neutral overall for vehicle capacity and traffic congestion. NGT is predicated upon maintenance of private vehicle journeys at their current, unsustainable levels, and in many areas of the NGT route the relatively poor quality of provision for walking and cycling is due to the necessity to preserve space and junction capacity for drivers.

The NGT Major Scheme Business case forecasts a mode shift of over 150k car journeys and about 400k park and ride journeys per year by 2031. And yet this predicted removal of car journeys on the corridor has not been backed up by a reduction of expected demand for vehicle capacity at junctions on the route. Without this, it is likely that no long term reduction in car journeys will occur, as research has shown that creating additional vehicle capacity has at best a short term benefit with additional capacity absorbed by additional journeys within 2-5 years.[iv] Without measures to curb car use, a key opportunity to reinforce and embed the mode shift from car journeys will be lost (objection point 6).

Despite this shift of car journeys, the business case indicates that the majority of NGT passengers will be today’s bus users: if one of the aims of NGT is to support a mode shift to more efficient and sustainable transport modes, it seems likely to fail in this regard. And if this isn’t its key aim, what is the point?

During 2014 Leeds hosted the Grand Départ for the Tour de France; and £30m of investment from the Cycle City Ambition fund was announced for the Leeds and Bradford CityConnect scheme. Building on these two opportunities, a long term cycling strategy and a regional Tour de France Legacy strategy have been published, aiming to raise cycling mode share in Leeds and West Yorkshire by at least an order of magnitude.

Councillor Keith Wakefield, leader of Leeds City Council stated his support for cycling in a recent local news release: “We are firmly committed to maximising every possible benefit from the city hosting the Tour de France. As we outlined in our legacy vision, we want to put cycling at the heart of the future of Leeds … to bring about significant benefits in a range of areas such as health and wellbeing, transport, leisure, the environment and the economy. That is our long-term aim to do everything we can to encourage and help as many people as possible to get cycling.”

We are starting from a low base: mode share for cycle commuting in Leeds is among the lowest of the core cities with 2011 census data showing just 1.1% of adults cycle to work compared to 2.6% in London and a national average for England and Wales of 1.9% Over the period from 2001 to 2011, cycle commuting mode share in Leeds rose by 0.5 percentage points but car driver or passenger trips rose by 2.5 points. There is a pressing need to address our car dependence.

Specific points in response to the promoters’ proofs and rebuttals

The promoters have highlighted (eg in their rebuttal arguments 4, 5 and 8) the benefits of NGT to cycling in comparison with the situation today. This assumes that today’s situation is an acceptable one. In contrast, the experience of my members indicates that cycling takes place in Leeds not because of the provision made for cycling, but in spite of it.

For example, cycle lanes are provided on some stretches of the A660 on the Northern section of NGT; but at the busiest and most difficult stretches: around Hyde Park Corner, and in the centre of Headingley, cycle provision disappears completely. As Mr Robertson indicated in his evidence to this inquiry, the centre of Headingley is an area where significant “jostling” takes place. Traffic flow at either end of this short stretch apparently means two vehicle lanes must be provided, and therefore no help can be offered to cyclists at all. “Jostling” with other cyclists is one thing: jostling with cars, buses and HGVs quite another. The recommended route for cycling between Leeds and Headingley is the City Centre to West Park route of the “Core Cycle Network” which is a sort of a magical mystery tour of the local side streets: indirect, fiddly, and according to an academic at the Leeds Institute of Transport Studies, actively dangerous in at least one location.

In the city centre, cyclists are squeezed between the pedestrianized city centre, and the Loop road. We are invited to use the Public Transport Box which includes Park Row and Boar Lane, and the whole of this Box is usually congested with buses and delivery traffic and is devoid of cycle infrastructure of any kind.

On the South side of Leeds, cycle provision is again almost non-existent; numbers of cyclists are low and those that are seen are often on the footway. Hunslet Road is two lanes in each direction for much of its length, and busy with fast, heavy traffic and no cycle lanes.

The benefits of cycling are well evidenced, and investment in cycling has excellent cost effectiveness: for every £1 pound spent on cycling initiatives £4 is saved in costs to the NHS and value to the economy.[v]”

To give an example of a successful intervention, Seville, with a population of 700 thousand people, implemented 80 miles of high quality bike lanes over a 6 year period for a cost of approx 50 million Euro. This increased cycling journeys from under 3k per day to over 70k per day, from a modal share of less than 0.5% to around 7%. In addition, proportion of female cyclists has risen from 20% to 50%.

Portland in Oregon built 300 miles of high quality cycle infrastructure for £40 million, which increased modal share of bicycle journeys to 8%. The payback on Portland's investment, purely in terms of reduced health costs, is reckoned at 6.5 to 1.[vi]

The recent application by Leeds and Bradford to the Cycle City Ambition fund was able to draw on estimated benefits of over £50m through inclusion of walking and cycling in the cost benefit analysis. The NGT major scheme business case chose to ignore the possible benefits of improving the environment and didn’t bother to include monetised benefits from walking and cycling through amenity, health improvements and reduced absenteeism, reduced traffic collisions, noise reduction, and air quality improvements.

In the promoters’ rebuttal (objection point 4, rebuttalargument 2), they provide an analysis by transport consultant Steer Davies Gleave of the benefits of NGT for walking and cycling. SDG conclude “For cyclists the overall impact is slight positive but this marks some local strong positives (new urban realm improvements) and a number of adverse impacts”. “For pedestrians there are a lot of positives and few adverse impacts. It is, however, noted that single stage straight crossings closer to desire lines are generally preferred by pedestrians over the mostly staged, staggered and guard-railed crossings proposed”.

Firstly I’d note that SDG views NGT as “slight positive” for cycling, rather than the “significant provision for cyclists” stated in the promoters’ rebuttal, unless he means significantly more than nothing. And the inclusion of adverse impacts are hardly what we need in a city that claims to support cycling but still has a mode share of less than 2%. The areas scoring negative numbers in SDG’s analysis - and therefore are worse for cycling than today - include the inbound approach to Hyde Park Corner, and the main stretch through the city centre from Portland Way to Lower Briggate, some of the busiest stretches where decent provision is most needed.

The SDG report outlines monetised benefits of £27.85 million at 2010 prices due to increased cycling including a shift from car trips. However this is a direct contradiction with the original NGT major scheme business case, which actually forecasts a reduction in active travel, through mode shift to NGT, of almost 1m trips per year by 2031[vii], (objection point 5) and the health costs of this shift are of course not included in the cost benefit analysis for NGT. When I queried this, I received the following reply:

“As you identify, the Business Case Review could be read to suggest that NGT will result in a reduction in the overall number of people using active modes (…walking and cycling). This element of the Business Case Review was prepared by Steer Davies Gleave and was a subject in the evidence of Neil Chadwick who was cross-examined on this matter. Mr Chadwick explained to the inquiry that the representation of active modes in the Leeds Transport Model (the model that underpins the assessment in the Business Case Review) is not a full and comprehensive representation of the use of active modes in Leeds. Therefore, while the model forecasts a reduction in active mode trips represented, this should not be taken as a saying there will be an overall reduction in active mode use. Indeed, as the assessment appended to the rebuttal sets out, it is expected that the cycling infrastructure associated with NGT will support increased cycle use along the NGT corridor.”

My conclusion from this is that I have no reason to believe that any of the figures on active travel are reliable, and it appears that despite the massive beneficial impact they can have on health and cost benefit appraisal, active travel modes have not received the attention they deserve from the promoters.

It is clear from surveys of public opinion that the key barrier to cycling is fear of traffic[viii] and that significantly increasing cycling mode share will require big changes to the physical environment. In a recent survey of existing cyclists in Leeds we found that mandatory cycle lanes were preferred to shared bus and cycle lanes. For mandatory cycle lanes 60% said “very helpful”, shared bus/cycle lanes 47% said “very helpful” – this is existing cyclists, not those who are currently too scared to cycle.

Whilst it’s impossible to determine how people will feel about sharing lanes with NGT vehicles, comments from our members indicate serious concerns about sharing with NGT, especially among women and children. The recent nationwide “Space for Cycling” campaign, which has been very popular with cyclists, calls on local authorities to provide suitable infrastructure for cycling, including protected space on main roads and at junctions – not currently a feature of the vast majority of the NGT route.

Provision of cycle infrastructure should seek to be inclusive: that is, to be suitable for use by older and younger people, men and women, all ethnic groups and people of varying physical fitness and with disabilities. This is not currently the case for cycling in the UK and currently cycling is very unrepresentative of the general population. Interventions such as Advance Stop Zones, and cycle lanes requiring cyclists to move into a right-hand lane to negotiate busy junctions do not cater for the majority. Comparisons with other nations show that when high quality infrastructure is provided, cycling becomes available to all, regardless of gender, age, ethnicity and disability.

We don’t assume that providing high quality cycle infrastructure needs to mean a separate cycle track on every street: about 50% of cycling in the Netherlands is on roads shared with vehicles. But if we want the majority to be able to choose cycling, we must provide separate cycle tracks alongside main roads, such as those covered by most of the NGT route.

The promoters have now, through our discussions, included the bare minimum of cycling provision, most of which will help most existing cyclists. But they do not adhere to current best practice let alone aim for a future with inclusive cycling infrastructure.

The promoters say that they adhere to guidance such as LTN2/08. Even if this were strictly true it is not sufficient for today’s environment where it is recognised that LTN2/08 now falls below the standard required to grow cycling significantly. On-road cycle lanes that can be encroached on by vehicles, and fiddly toucan crossings are not sufficient to make cycling appealing to the majority. Leeds’ own cycling scheme CityConnect has moved far beyond LTN2/08 in recognition of its ineffectiveness, and local governments including Manchester and TfL in London are producing new standards and guidelines to meet this challenge.

I appreciate the lack of up to date guidance leaves local authorities in a difficult position when they are designing cycle routes. But it has been possible for the Cycle City Ambition projects to plan safe, separated cycle tracks alongside main roads, with priority over side roads, under the current regulations.

LTN 2/08 Table 2.3 gives ideal minimum total widths for vehicles passing cyclists: a bus or HGV safely passing a cyclist at 20mph requires a total width of 4.6m; at 30mph, 5.05m. In the design section, “6.2.2 A bus lane width of 4.5 metres will enable buses to safely pass cyclists without having to leave the lane. Widths below 4 metres generally result in buses moving out of the lane when overtaking cyclists… Widths below 4 metres are not recommended for bus lanes physically bounded on both sides, unless they are over very short distances”. Given the likelihood of a queue of stationary vehicles in the next lane, and the articulated nature of the NGT vehicles, I think we should assume sufficient space needs to be given for NGT to pass safely within the lane. 4.2 metres is not mentioned in LTN2/08 and seems to be a compromise chosen by the promoters between the 4.5m that should be provided and the 4m which is insufficient.

A recent model created by transport researcher Rachel Aldred[ix] suggests that buses and cycles flow better when they are physically separated, and that leap-frogging of cyclists and buses (and this may also apply to NGT) will lead to delays for the buses or NGT. This suggests that contrary to the design principles employed in NGT, a physically separated cycle track alongside the NGT lane could be beneficial for NGT as well as for cyclists.

Continuing with LTN2/08, “7.4.2 Cycle lanes should be 2m wide on busy roads, or where traffic is travelling in excess of 40mph. A minimum width of 1.5m may be generally acceptable on roads with a 30mph limit. … Cyclists can overtake each other within a 2 metre wide lane and easily remain within it when looking back to check for traffic, or when avoiding kerbside drainage grates etc.”

In addition, when queueing traffic is likely, there is a considerable danger to straight-on cyclists from right-turning vehicles crossing their path. A wider cycle lane increases visibility and gives more room for manoeuvre in the event of a vehicle starting to turn.

To summarise, on the busiest cycle route in Leeds, with over 500 cyclists daily at the peak, (one third of all cycle commuting journeys in Leeds), the promoters seem satisfied with a road layout where cyclists cannot safely overtake one another. We do not regard 1.5m to be generally sufficient for a busy cycle lane on a main road.

From the promoter’s Rebuttal (argument 3), “As set out in my Proof the design does follow the guidance within LTN2/08. I consider the widths in the design to be adequate and note that wider bus/cycle lanes would impact on third parties wither with additional land take or through operational delays to street users.” So the safety of cyclists comes second to “operational delays to street users”. I think it’s clear where the compromises are being made.

In our view, NGT should at least include the recommended widths for cycling: 2m for an on-road cycle path on a main road, and 4.5m (given the articulated nature of NGT vehicles) for a shared NGT and cycle or NGT, bus, taxi and cycle lane, with a 1.5m cycle path marked within it to help bus and NGT drivers to pass safely. This would allow upgrade to separated cycle paths at a later date or at detailed design.

In responding to our Proofs of Evidence with (rebuttal argument 3), the promoters deny knowledge of the Design Basis Statement that we were informed underpinned the design parameters. In recent discussions with the design team, the NGT team referred to a “Cycle Policy Statement” which has also not been published and was not made available when I requested it.

At Cycle Consultation Forum in April 2014[x], members of the NGT team presented details from this policy, including stated “desirable” width of 4.2m for combined NGT/bus/cycle lane and 2m for cycle lane, and “absolute minimum” of 4m for combined NGT/bus/cycle lane and 1.5m for cycle lane. While we regard 4.2m as insufficient for a combined NGT/bus/cycle lane it is worrying that this is listed as a “desirable” width, leaving the door open to return to just 4m shared NGT/bus/taxi/cycle lane at a later design stage.

Objection points 11 and 12 have been removed by agreement with the promoters

Proof of Evidence point 3a (Original objection point 13) and rebuttal arguments 4 and 5:

The NGT plans include a change to the layout of this junction that increases the danger to cyclists. The junction as currently laid out is misleading as pointed out by the promoters in their rebuttal (argument 4), however the proposed solution is to include an additional pedestrian crossing island and left turn filter lane for general traffic. This makes negotiating the junction slower and more inconvenient for pedestrians, and introduces a significant danger for cyclists in a very large radius on the left turn into Shaw Lane from Otley Road (inbound). As described in the rebuttal, “Cyclists have the choice between using this lane or using the bus/NGT/cycle gate to move safely into the ahead only lane” – that is, I can either adopt a central position in the left lane, or adopt a central position in the right lane (the “bus lane dither”): it is generally acknowledged that “taking the lane” at a busy junction is a manoeuvre that only confident cyclists will attempt. The less confident would be required to dismount and navigate two phases of guard-railed 90 degree offset pedestrian crossings to make a straight on movement.

The danger from left-turning large vehicles at junctions like this is well known and is responsible for more cyclist fatalities than any other situation. The safety of cyclists and pedestrians should take priority over considerations of junction capacity for general traffic at this location.

Proof of Evidence point 3b (Original objection point 14) and rebuttal arguments 6 and 7:

All turning movements will be banned at Hyde Park corner: this potentially affects a very large number of people cycling from the student residential areas around Headingley towards the universities. It blocks a desire line for cyclists wishing to use Moorland Road and existing cycle facilities on Woodhouse Moor, which carry over 250 cyclists per day in peak morning hours. The current plan shows cycles and motor traffic diverted to other roads for all turning manoeuvres.

The proposed banning of cycle turns potentially leads to conflict between cyclists and pedestrians and there is a risk that some cyclists and pedestrians will not respect the intended movements as some are indirect and inconvenient. The high volume of cycle traffic here includes overseas students potentially less familiar with UK road signage and layouts, and simple solutions to this junction are needed to prevent collisions. For many overseas students they might expect the provision of safe, direct cycle routes between student residences and the university.

Management of private vehicle traffic is currently prioritised over cycle and pedestrian safety at this location, including the omission of a pedestrian crossing on the fourth side of the junction where there are frequent near-misses.

Through discussion with the Council and scheme representatives, the designers have proposed a Danish-style two stage right turn for southbound traffic wanting to turn into Hyde Park Road. However this is not included on the current plans and it is not clear that it can be provided.

From 2005 to 2012 there were fifteen reported accidents causing injury to cyclists and pedestrians at this junction, with five pedestrians and one cyclist seriously injured. The safety of cyclists and pedestrians must have priority over vehicle capacity at this location.

Proof of Evidence point 3c (Original objection point 15) and rebuttal arguments 8 and 9:

Current provision for walking and cycling at this key location in the heart of the city is inadequate and the proposals for NGT do very little to improve this. Little consideration is given to the considerable demand for cycling and walking capacity between the railway station and locations to the northern and eastern sides of the square. General traffic on the loop road is prioritised, leading to a dangerous bottleneck of pedestrians and cyclists at the large toucan crossing of Bishopgate Street and an area blighted by through traffic. There have been nine pedestrian casualties here since 2005. Remodelling of parts of the square during implementation of the NGT project provides an opportunity to deliver safe and convenient cycle and pedestrians routes that are not in conflict with each other. Creating a calmer environment with less reliance on multiple lanes of general traffic would benefit local businesses and services and create a pleasant space to welcome visitors arriving into the city by rail.

The rebuttal states “Leeds City Council has already demonstrated its commitment to pedestrians and cyclists on Bishopgate Street by reducing the number of lanes from 3 to 2, adding a cycle lane and increasing the size of pedestrian refuges”. On the contrary this demonstrates the Council’s complete lack of understanding of cycle design. The pedestrian refuges have been increased in size, but the pedestrian green light is so infrequent that the crossing is jam-packed at busy times and impossible to use as a toucan crossing. On the approach from Bishopgate Street, the council have added a cycle lane up the left hand side of two traffic lanes that then split into four (“multiple lanes” referred to in the rebuttal), meaning that it is almost impossible to cross these lanes rightwards to join the infrastructure in the centre of City Square, and similarly impossible to follow the loop road straight on towards King’s Street. In fact the head of Chapel Allerton WI was knocked off her bike at this location and luckily fell to her left, otherwise she would have been run over by a bus. An ASZ is provided but the timing of the lights means that coming from the South it is impossible to get into the ASZ before the lights turn green, unless you sprint like Chris Hoy. The only safe manoeuvre from this cycle lane is to turn left into the Queen’s Hotel.

Following a discussion with the NGT team last week, detailed objection points a, b, c, f, g, h, k (subject to declassification/20mph) n, o, p q, and s have been removed due to improvements to the designs. Detailed points d, e, i, j, l, m, r and t remain.

As you have already identified, Leeds could have implemented better provision for buses over much of this route without the need for the massively disruptive and costly NGT. Similarly, a high quality cycling scheme could have been introduced for a fraction of the budget and with much better chance of a positive return on investment. But for either of both of these to be implemented to a high standard and effective in changing people’s transport choices, a reduction in private vehicle capacity would be a prerequisite. While this would be in line with Leeds and West Yorkshire’s stated policies, it doesn’t seem to have been regarded as a viable option by the promoters.

The assumptions underpinning NGT treat all transport modes other than NGT as if they are equal, but cost-benefit analysis from Denmark shows that when a person chooses to cycle there is a clear gain to society of about 1.2 Danish Kroner per kilometer cycled. Conversely, society suffers a net loss of 0.7 Danish Kroner per kilometre driven by car .[ii] It is not appropriate to preserve our right to drive short distances, when this leads to serious compromises in the quality of infrastructure for cycling and walking.

While the promoters assure us that NGT is “slightly positive” for cycling as determined by Steer Davies Gleave, this appears to have been partly as an unintentional by-product of designing what is effectively a glorified bus lane, and partly through our continued pressure – my members investing of huge amounts of their own time and effort to influence the design. A firm commitment to the most sustainable and efficient ways of travelling – walking and cycling – is not evident.

Before plans for NGT were drawn up, all transport options should have been considered and the relative costs to society of over-reliance on car use and undervaluing of active modes should been taken into account. A solution favourable to walking and cycling could have been devised, which would have generated an overwhelmingly positive cost benefit appraisal. Instead the promoters chose to focus on minimising negative impact on private vehicle capacity and were therefore unable to design a scheme that significantly benefits cycling.